BV ERCOT Gas Study Report March 2012

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    GASCURTAILMENTRISKSTUDY

    Preparedfor

    TheElectricReliabilityCouncilofTexas

    MARCH2012

    Black&VeatchHoldingCompany2011.Allrightsreserved.

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    TheElectricReliabilityCouncilofTexas|GASCURTAILMENTRISKSTUDY

    BLACK&VEATCH|TableofContents i

    TableofContentsTableofContents..........................................................................................................i

    1.0ExecutiveSummary............................................................................................3

    2.0Introduction..........................................................................................................8

    2.1 Organization of this Report ...................................................................................... 9

    3.0ReviewofHistoricalCurtailments..............................................................11

    3.1 Data Availability & Sources .................................................................................... 12

    3.2 Summary of Historical Curtailments & Causes .............................................. 13

    3.3 Best Practices & Lessons to be Learned ............................................................ 16

    4.0NaturalGasInfrastructure&Market.........................................................18

    4.1 Interstate Pipelines................................................................................................... 18

    4.2 Intrastate Pipelines................................................................................................... 19

    4.3 Natural Gas Storage Facilities .............................................................................. 20

    4.4 Role of Gas Compressors ........................................................................................ 21

    4.5 Survey Results of Natural Gas Infrastructure Serving ERCOT

    Generators ............................................................................................................................ 22

    5.0 RiskAssessment -Approach&Assumptions........................................26

    5.1 Summary of Approach ............................................................................................. 26

    5.2 Tools and Software .................................................................................................... 29

    5.3 Global Assumptions ................................................................................................... 31

    6.0 RiskAssessment- Results.............................................................................35

    6.1 Implications from Freezing Weather ................................................................ 35

    6.2 Implications from Pipeline Disruption ............................................................. 46

    6.3 Implications from Tropical Cyclones ................................................................ 51

    Appendices..................................................................................................................57

    Appendix A Data Sources ............................................................................................ 57

    Appendix B Weather Analysis .................................................................................... 60

    Appendix C Statistical Details .................................................................................... 66

    Appendix D Texas Railroad Commission Curtailment Plan .......................... 69

    Appendix E Liquidity in Texas Natural Gas Market ......................................... 71

    Appendix F December 1983 event simulated for 20112012 ..................... 86

    Glossary ................................................................................................................................. 99

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    BLACK&VEATCH|TableofContents ii

    LISTOFTABLES

    Table 1 Sources of curtailment information. ................................................................. 12

    Table 2 Indicative numbers of natural gas compressors serving the

    Texas gas pipeline infrastructure................................................................. 22

    Table 3. Sizes of curtailmentincident data sets available for

    definition of events and probabilistic risk analyses. ............................ 28

    Table 4. Weather stations used for freezingweather analyses of

    ERCOT. ..................................................................................................................... 35

    Table 5. Winter (Dec, Jan, Feb) daily HDD correlations among the

    four heavyload Weather Zones. ................................................................... 35

    Table 6. Winter (Dec, Jan, Feb) daily HDD correlations between

    ERCOT and other gasdemand regions. ..................................................... 36

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    BLACK&VEATCH|TableofContents iii

    LISTOFFIGURES

    Figure 1 Black & Veatch Approach to Delivery of Phase1 Study ............................. 9

    Figure 2 Numbers of documented gascurtailment incidents studied. ................ 13

    Figure 3 Fishbone diagram for possible freezingweather causes of

    gas curtailments. ................................................................................................. 14

    Figure 4 Fishbone diagram for possible pipelinerelated causes of

    gas curtailments. ................................................................................................. 15

    Figure 5 Fishbone diagram for possible tropicalcyclonerelated

    causes of gas curtailments. ............................................................................. 16

    Figure 6 Interstate Natural Gas Pipelines Serving ERCOT Generators ............... 19

    Figure 7 Intrastate Natural Gas Pipelines Serving ERCOT Generators ................ 20

    Figure 8 Natural Gas Storage Assets in ERCOTs Service Region ............................ 21

    Figure 9 Natural Gas Pipelines Serving ERCOT Electric Generators ..................... 23

    Figure 10 Number of Pipeline Interconnects for Each Electric

    Generator ............................................................................................................... 24

    Figure 11 Pipeline Capacity as Percentage of Peak Needs ........................................ 25

    Figure 12 SupplyDemand Fundamentals. ....................................................................... 30

    Figure 13 Black & Veatch Integrated Market Modeling Process............................. 31

    Figure 14 Lower48 Natural Gas Supply Projection .................................................. 32

    Figure 15 Texas Natural Gas Supply Projections ........................................................ 32

    Figure 16 Lower48 Natural Gas Demand Projection .............................................. 33

    Figure 17 Texas Natural Gas Demand Projection ....................................................... 34

    Figure 18 PowerOutage Risk curve (freezing weather) annualized,

    including error envelope beginning at the 55th percentileof probability (mode or peak) of the risk distribution. ....................... 38

    Figure 19. Loss of onshore gas production during extreme freezing

    events. ...................................................................................................................... 39

    Figure 20 PowerOutage Risk curves for freezing weather with

    projected future trends .................................................................................... 40

    Figure 21. Incremental Daily Demand By Scenario. .................................................... 42

    Figure 22. Onshore Gulf Coast Production and Impacts from

    Wellhead Freezeoffs. ........................................................................................ 43

    Figure 24. Projected Intrastate Pipeline Utilization, North Texas to

    Houston. .................................................................................................................. 44

    Figure 25. Projected Intrastate Pipeline Utilization, West Texas to

    North Texas. .......................................................................................................... 45

    Figure 26. Projected Intrastate Pipeline Utilization, South Texas to

    Houston. .................................................................................................................. 45

    Figure 27. Definition of the pipeline incidents available for risk

    analysis. ................................................................................................................... 46

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    BLACK&VEATCH|TableofContents iv

    Figure 28. PowerOutage Risk curve for pipeline infrastructure

    issues. ....................................................................................................................... 47

    Figure 29 Pipeline Capacity Comparison Across Pipeline Disruption

    Scenarios ................................................................................................................ 50

    Figure 30. Indicative Pipeline Utilization Across Pipeline Disruption

    Scenarios. ............................................................................................................... 51

    Figure 31 Observed frequency of tropical cyclones and their impacts

    on gas production in the Gulf of Mexico .................................................... 52

    Figure 32. PowerOutage Risk curves derived for annualized tropical

    cyclone frequencies. ......................................................................................... 53

    Figure 33. Temporary gas demand destruction caused by Hurricane

    Ike in 2008. Data from Energy Information

    Administration. .................................................................................................... 54

    Figure 34. Gulf of Mexico Gas Production Affected by Tropical

    Cyclones. ................................................................................................................. 55

    Figure 35. Loss of Gas Production Anticipated for Tropical Cyclone

    as the Causal Events. .......................................................................................... 56

    Figure A1: Process used to collect and sort information about gas

    curtailments. ......................................................................................................... 57

    Figure E1: Texas Natural Gas Pricing Points. .................................................................. 78

    Figure E2: Criteria for Platts Tier Rankings for Natural Gas Pricing

    Points. ...................................................................................................................... 79

    Figure E3: Historical Platts Tier Rankings for Texas Pricing Points ..................... 79

    Figure E4: Traded Volumes and Deals of Natural Gas Reported at

    Texas Pricing Points: Monthly Averages of Daily Volumes. .............. 80Figure E5: Daily Traded Volumes Reported at Texas Natural Gas

    Pricing Points: September 2001. .................................................................. 81

    Figure E6: Daily Traded Volumes Reported at Texas Natural Gas

    Pricing Points: February 2003. ..................................................................... 82

    Figure E7: Daily Traded Volumes Reported at Texas Natural Gas

    Pricing Points: August through October 2005. ....................................... 83

    Figure E8: Daily Traded Volumes and Deals Reported at Texas

    Natural Gas Pricing Points: September 2008 .......................................... 84

    Figure E9: Daily Traded Volumes and Deals Reported at Texas

    Natural Gas Pricing Points: January through March 2011. ................ 85

    Figure F1. Notably cold winters affecting ERCOT since 1950................................. 86

    Figure F2. Lengths of freezingweather events affecting ERCOT. ......................... 87

    Figure F3. Daily temperatures in north Texas during December 1983 .............. 88

    Figure F4. Freezing temperature patterns in major historical events

    affecting ERCOT. .................................................................................................. 88

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    BLACK&VEATCH|TableofContents v

    Figure F5. Weather stations used for the December 1983 analyses

    across ERCOT........................................................................................................ 89

    Figure F6. Freezeoff risks at an onshore natural gas wellhead. ........................... 91

    Figure F7. Significance of physical temperature relative to wind chill. .............. 92

    Figure F8. Daily wind chill values across ERCOT during December

    1983. ......................................................................................................................... 92

    Figure F9. Natural gas production losses during the February 2011

    freezingweather event. ................................................................................... 93

    Figure F10. Empirical productionloss models based on production

    weather data regressions. ............................................................................... 94

    Figure F11. Theoretical gasproduction losses in Feb 2012 under

    Dec 1983 weather conditions. ....................................................................... 95

    Figure F12. Daily winter freeze risks across ERCOT compared with

    December 1983 event. ...................................................................................... 96

    Figure F13. Daily winter wind risks across ERCOT compared withDecember 1983 event. ...................................................................................... 97

    Figure F14. Estimated Aggregate Loss of Generation Capacity .............................. 99

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    BLACK&VEATCH|1.0ExecutiveSummary 3

    1.0ExecutiveSummary

    This study presents the risk of gas supply curtailment to electric generators within the

    service region of the Electric Reliability Council of Texas (ERCOT) over a 1Year, 5Year and

    10Year time horizon. It reviews historical incidents of gas supply curtailment experienced

    by ERCOTs generators, examines the natural gas infrastructure serving these generators

    and assesses the risk of gas supply curtailment on a probabilistic and a fundamental

    supply/demand basis.

    Curtailment was defined for the purposes of this study as the loss of normally expected gas

    delivery as a consequence of supply or transportation interruptions caused by weather

    driven, contractual or operational issues.

    This study considers the physical capabilities of the natural gas infrastructure in serving

    electric generators rather than the contractual arrangements to serve electric generators

    with natural gas. Although there may be financial implications to procuring the gas supply

    needed, natural gas service is generally available to electric generators subject to the

    regulatory and physical constraints of the system. Further, studying contractual

    agreements which are subject to commercial negotiations and change through time, does

    not allow for a longer term view of the risk of natural gas curtailment to electric generators

    which is better captured from the perspective of the physical limitations of the natural gas

    infrastructure in serving the needs of electric generators.

    This study does not include or consider mitigating measures that have been or can be

    incorporated to reduce the risk of gas supply interruption for power generators. Therefore,

    this study takes a conservative view on the risk of gas curtailment to electric generators.There have been significant changes in the gas industry over the last 25 years, specifically,

    the pipelines typically no longer own the gas they transport and deliver, and there is an

    increased use of gas storage as a physical hedge against both supply and pricing volatility

    and to ensure deliverability. Combined with the greater liquidity in the natural gas market,

    in reality, when natural gas supply or delivery is impacted, the redundancy and

    interconnectedness in the natural gas market generally provides consumers (including

    electric generators) with alternate sources and routes for natural gas supply to partially or

    fully serve their needs. Pipeline linepack, natural gas storage and displacement of supply

    from other markets could all contribute to mitigate the risk of disruption of natural gas

    supply to electric generators within the ERCOT service region that are presented in this

    study.

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    BLACK&VEATCH|1.0ExecutiveSummary 4

    Historicalcurtailmentsdatarecordkeepingislimited

    This study examined historical

    records for gas supply curtailment

    from various sources including

    ERCOT, the National EnergyTechnology Laboratory (NETL) and

    the Railroad Commission of Texas

    (TRRC) and found severe limitations

    in capturing information about

    incidents of natural gas curtailment

    to electric generators. The leading

    cause of the gas supply curtailment

    incidents identified was freezing

    weather with existing TRRC

    regulations and/or pipeline contractual provisions contributing to gas supply curtailments

    to electric generators. Pipeline disruptions and tropical cyclones were inferred to have

    caused the other historical incidents of curtailment that were reviewed.

    ERCOTgeneratorsdemonstratereliabilityandredundancyofnaturalgassupply

    This study conducted a survey of

    electric generators within ERCOTs

    service region to assess their access to

    natural gas infrastructure to serve

    their gas demand. Based on survey

    responses, ERCOTs electric

    generators demonstrate reliability

    and redundancy of supply through

    their interconnections with multiple

    pipelines and access to a level of

    capacity that is well in excess of their

    peak natural gas needs. 60% of

    survey respondents (corresponding to 51,550 MW of nameplate capacity1)indicated

    interconnects with more than one natural gas pipeline. All the survey respondents that

    provided sufficient data to make an assessment of adequacy indicated access to capacity in

    excess of their peak needs.

    Naturalgaspipelineinfrastructureissufficienttomeetprojectedneeds

    Natural gas pipeline infrastructure serving ERCOT generators was found to be adequate to

    meet anticipated peak demand during the analysis period in the scenarios analyzed.

    1 The nameplate capacity is inclusive of generation capacity that is part of Private Use Networks which

    generally serve their own industrial loads rather than selling power into ERCOT.

    108

    10

    2

    54

    0

    20

    40

    60

    80

    100

    120

    GASCURTAILMENT/

    FREEZINGWEATHER

    GASCURTAILMENT/PIPELINE

    OPERATION

    GASCURTAILMENT/

    TROPICALCYCLONE

    GASCURTAILMENT/

    UNKNOWNCAUSE

    NumberofIncidents

    GasCurtailmentIncidents&Causes

    23

    11

    13

    4

    65

    7

    0

    5

    10

    15

    20

    25

    100%149% 150%199% 200%249% 250%299% 300%349% 350%399% >400%

    NumberofGenerators

    Capacityas%ofPeakDemand

    HistogramShowingPipelineCapacityas%ofPeakNeeds

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    BLACK&VEATCH|1.0ExecutiveSummary 5

    Although there is potential for isolated incidents, the fundamental supply/demand analysis

    undertaken in the study indicated the robustness of the natural gas pipeline infrastructure

    in meeting the needs of electric generators within ERCOT, even in the presence of strong

    competing demand from other markets and sectors.

    Risk

    from

    Freezing

    Weather-

    18%

    probability

    of

    having

    2000

    MW

    of

    capacity

    temporarilyunavailableduetogascurtailments

    Risk assessment, based on

    historical incidents of

    curtailment, indicates that in

    any given winter, there is an

    18% probability of supply

    disruption from lack of gas

    supply or

    contractual/regulatory defined

    curtailment impacting about2,000 MW generation capacity

    and about 90% probability of

    impacting about 350 MW.

    While freezing weather is the

    most impactful of the risk

    factors considered, the

    probability of gas supply curtailment due to freezing weather projected forward should be

    viewed together with associated mitigations namely, increased thermal protection of

    wellheads against freezeoffs and the priorities and revision of contractual curtailments

    initiated by freezing weather. Both wellhead thermal protection and alternative contractual

    provisions offer opportunities for assuring greater reliability of gas deliveries during coldwinter events.

    RiskfromPipelineDisruptions - 5%probabilityinthenear-termofhaving500MW

    ofgenerationcapacitytemporarilyunavailable

    Risk assessment of pipeline

    disruptions based on historical

    incidents of curtailment

    indicates that there is a 5%

    annual probability of losing

    500 MW as a consequence ofgas supply curtailment due to

    pipeline outages. Although risk

    assessment assumes that the

    entire anount of curtailed gas

    was required for power

    generation and no alternate

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    BLACK&VEATCH|1.0ExecutiveSummary 6

    supply was available, redundancy in pipeline capacity serving generators can reduce

    exposure to gas supply curtailment from pipeline disruptions.

    RiskfromTropicalCyclones

    - 13%probabilityinthe

    near-

    term

    of

    having

    1000

    MWofgenerationcapacity

    temporarilityunavailable

    Compared with the total

    volume of gas required for

    ERCOT power generation, the

    proportion of gas obtained

    from Gulf of Mexico (GOM)

    offshore production is small

    with less than 5% of the total

    ERCOT gas consumptiondepending on GOM

    production. Therefore, tropical cyclone impacts on ERCOTs power generation are

    relatively small. For perspective, on the 1Yr horizon there is a 13% risk of 1000 MW

    generation loss from tropical cyclone.

    Conclusions&recommendations

    Data availability placed constraints on understanding and analyzing historical gas supply

    curtailments to electric generators within ERCOTs service region. Increased coordination

    between natural gas and power industry regulating agencies could help ensure improved

    crosscapture of information as the role of natural gas as a fuel source for power generation

    continues to grow. If ERCOT is expected to monitor fuel impacts on the reliability of the

    electric grid, better data capture of curtailment incidents is needed.

    Some specific recommendations are listed below:

    ERCOT Operator logs were the most complete source reviewed in the study of incidentdata on natural gas supply disruption experienced by electric generators within ERCOT.

    It was observed that capture of natural gas curtailment incident information would be

    more complete and accurate with greater training of ERCOT operators to improve

    recognition of, and familiarity with, natural gas pipelines and utilities serving ERCOTs

    electric generators.

    This study included a survey of gasfired electric generators within ERCOTs serviceregion to assess their experience with natural gas supply disruption. It is recommended

    that standardized categories of gas delivery issues should be included as a regular report

    element in the annual reporting by generators to ERCOT. This will allow ERCOT to track

    and assess any trends associated with natural gas supply disruption to electric generators

    and to develop risk mitigation plans if a trend reflecting increasing disruption to electric

    generators is observed.

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    BLACK&VEATCH|1.0ExecutiveSummary 7

    This study recommends continued coordination between ERCOT and the RailroadCommission of Texas (TRRC) to facilitate better data capture including development of

    communication pathways and reports for gasdelivery incidents affecting power

    generation facilities.

    In addition to cost considerations associated with the decision to contract for firm orinterruptible gas service and /or have duel fuel supply, contractual agreements that

    require curtailment of gas supply to generators or mandatory curtailment policies as

    defined by the TRRC may inhibit a power generators ability and motivation to acquire

    firm gas supply. Review of these agreements and policies could help determine whether

    new policies or regulations are required to increase the reliability of ERCOT generation.

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    BLACK&VEATCH|2.0Introduction 8

    2.0IntroductionThe Electric Reliability Council of Texas (ERCOT) commissioned a Gas Curtailment Risk

    Study to evaluate the risk of natural gas supply disruptions to electric generating stations

    within the ERCOT administered portion of Texas.

    During the first week of February 2011, the Southwest experienced extremely cold weatherwith temperatures falling by as much as 50 degrees over an eighteenhour period in various

    cities in Texas. This extreme cold event saw low temperatures in the DallasFt. Worth area

    dipping to 13 F which, according to our probabilistic analysis, was an event with a winter

    time daily probability of less than 1%. During the first four days of February, 210 individual

    generating units within ERCOTs service region experienced disruption of their normal

    generation operations due to a variety of factors. The scale of generation loss led to

    controlled load shedding that impacted as many as 4.4 million customers2 during the event.

    A majority of the generation losses experienced occurred due to problems related to plant

    operation including frozen sensing lines, frozen equipment, frozen water lines, frozen

    valves, and blade icing. Extreme low temperature events in 1989 and 2003 similarly

    created conditions resulting in loss of generation in ERCOT. A FERCNERC investigationfound that, although the generation loss associated with these extreme weather events was

    not primarily driven by gas supply curtailment3, natural gas supply was impacted as a result

    of weather and contributed to the loss of generation.

    By fuel type, about 38% of ERCOTs annual average generation is currently accomplished

    with natural gas.4 Gasfired generation capacity within ERCOT is projected to increase by

    over 15,000 MW in the next 10 years. With natural gas share of electric generation within

    ERCOT being poised to increase to 50% over the next 10 years and beyond, it is important

    to understand the risks faced by electric generators due to potential disruptions in natural

    gas supply.

    This study is intended to increase ERCOTs understanding of the risks of generation loss

    from gas supply curtailment in the future and to consider potential mitigation measures

    that ERCOT can pursue to reduce risks arising from these curtailments. The study is also

    intended to assist ERCOT to objectively assess the costs and benefits of planning operations

    for mitigating gas supply curtailment risk to its electric generators.

    The scope covered by this study is summarized below:

    2Report on Outages and Curtailments During the Southwest Cold Weather Event of February 1-5, 2011,Federal Energy Regulatory Commission (FERC) and North American Electric Reliability Coporation

    (NERC), August 2011.3 It was stated that For the Southwest as a whole, 67 percent of the generator failures (by MWh) were due

    directly to weather-related causes, including frozen sensing lines, frozen equipment, frozen water lines,

    frozen valves, blade icing, low temperature cutoff limits, and the like. (p. 8). Report on Outages and

    Curtailments During the Southwest Cold Weather Event of February 1-5, 2011, Federal Energy Regulatory

    Commission (FERC) and North American electric Reliability Coporation (NERC), August 2011, 357 p.4 ERCOT (2011b) Data file: GenerationByFuelType_2002-2010.xls.http://www.ercot.com/content/news/presentations/2011/GenerationByFuelType_20022010.xls.

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    BLACK&VEATCH|2.0Introduction 9

    Deliverable 1 Review past natural gas interruptions impacting electric generation forinsights.

    Deliverable 2 For pipeline systems that serve generation, survey pipeline physicallimitations to providing natural gas to electric generation in ERCOT.

    Deliverable 3 Review scenarios in which ERCOT natural gas supply to electricgenerating stations could be significantly limited, including conditions of severe cold

    temperature combined with high wind speeds. Calculate the risk (assess probability) of

    such events in the near (1 to 5 year) and mid (5 to 10 year) timeframe.

    Black & Veatchs approach to meeting the requirements of the three deliverables was

    designed to collect, process and systematically analyze the data required to estimate the

    risk of gas supply curtailment to the electric generators within ERCOTs service region and

    is illustrated in Figure 1.

    Figure1Black&VeatchApproachtoDeliveryofPhase1Study

    2.1ORGANIZATIONOFTHISREPORT

    The remainder of this report is organized as follows:

    Section3: Review of Historical Curtailment Summary of our review of the historically

    reported incidents of natural gas curtailments within ERCOT.

    Section4: Natural Gas Infrastructure Summary of the natural gas infrastructure serving

    electric generators within ERCOT s service region.

    1. CompilePastNatural

    Gas

    Interruptions

    for

    PowerGeneration

    A. Events

    (numbers&types)

    B. CausalFactors

    C. LessonsLearned

    2. SurveyGasPipeline

    Data&Performance

    A. Transmission

    B. LDCs

    C. Storage

    MapoverofPipelinestoGasFiredGenerators

    ReferenceDatabaseofRealizedRisksandConsequences

    3. ConstructGas

    CurtailmentScenarios

    A. ExogenousRisksB. ProbabilisticRisk

    Analyses:5 and10yrHorizons

    C. ErrorEstimationsforProbabilisticRiskAnalyses

    IdentificationofScenarios

    S ev er eWeather Infrastructure

    Disruptions

    ProbabilisticAnalysisofScenarios

    PalisadeDecisionToolsmodeling

    AssessingImpactonNaturalGasService

    ModelingwithGPCM

    D. ERCOTSpecificRiskedCurtailments

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    BLACK&VEATCH|2.0Introduction 10

    Section5: Risk Assessment Approach & Assumptions Overview of overall approach and

    analytical tools and a list of key assumptions underlying Black & Veatchs analysis.

    Section6:Risk Assessment Results Discussion on analytical approach, scenarios

    examined and the results of risk assessment

    Finally, we include Appendices that provide more detailed descriptions, information andresults from the study.

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    BLACK&VEATCH|3.0ReviewofHistoricalCurtailments 11

    3.0ReviewofHistoricalCurtailmentsAn understanding of ERCOTs historical experience with natural gas curtailments is an

    important first step while examining the risk of any potential future disruptions to natural

    gas supply to electric generators within ERCOTs service region. We undertook a review of

    available historical data on natural gas curtailment incidents in order to collate and examine

    the experience to date with natural gas curtailment to electric generators.

    It should be noted that the term curtailment has different definitions depending on the

    industry and the agency that utilizes it. The Federal Energy Regulatory Commission (FERC),

    National Energy Technology Laboratory (NETL) and the Railroad Commission of Texas

    (TRRC) each has a different definition and understanding of the term curtailment as it is

    applied within their jurisdictions. For the purpose of this study, the working definition for

    curtailment that is Lossofnormallyexpectedgasdeliveryasaconsequenceofsupplyor

    transportationinterruptionscausedbyweather-driven,contractualoroperationalissues.

    Black & Veatch conducted research, using publiclyavailable information sources, to gather

    facts about historical cases of natural gas delivery interruptions within Texas that haveimpacted gasfired electric power generation. It should be noted that gas supply

    interruptions also can occur due to contractual provisions, TRRC defined regulations

    requiring disruptions of gas supply to power generators, as well as nondelivery of

    contracted supply5.

    Black & Veatch also worked with ERCOT to locate event data that is relevant to natural gas

    supply reliability. Historical ERCOT Monthly Operations Reports6, NERC System

    Disturbance Reports7, various FERC issued reports and historical pipeline operational

    information were sources of timeline information. In addition, ERCOT issued a survey

    questionnaire prepared by Black & Veatch to the natural gasfired electric generators within

    its service region seeking information on natural gas curtailments experienced by thegenerators during their operational history. The information gathered from these various

    sources were reviewed to compile chronological timelines for events involving curtailments

    or other disturbances of natural gas supplies to generation facilities. Although the focus of

    the study was on the ERCOT region, gasrelated incidents elsewhere were reviewed to the

    extent that they offer insights into issues relevant to ERCOT.

    For each occurrence of natural gas interruption that was identified, Black & Veatch

    examined the causal factors leading to the gas interruption. It should be noted that gaps in

    data availability and historical recordkeeping placed constraints on examining and

    accurately determining the cause of every incident of curtailment that was reviewed.

    Causal factors that were investigated include:

    Severe cold weather conditions in ERCOTSevere cold weather conditions in regions of competing gas demand5 TRRC Gas Curtailment Plan of 1973. Oil and Gas Docket, Gas Utilities Division, No. 20-62, 505,

    Docket No. 489, January 5, 1973. http://www.rrc.state.tx.us/meetings/dockets/docket489.php6 ERCOT Operations Monthly Reports. http://www.ercot.com/mktinfo/reports/omr/7 NERC System Disturbance Reports. http://www.nerc.com/page.php?cid=5|66

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    BLACK&VEATCH|3.0ReviewofHistoricalCurtailments 12

    Operational interruptions caused by pipeline outagesTropical cyclones (hurricanes, tropical storms and tropical depressions)OtherBlack & Veatch examined the common threads linking the instances of natural gas

    interruption identified and their causes to identify lessons that can be learned by ERCOT

    from these historic experiences.

    3.1DATAAVAILABILITY&SOURCES

    Historical records of natural gas curtailment to electric generators were found during our

    review to be limited. Our review found that most of the data available was for the last

    decade rather than for previous time periods, reflecting better record keeping in more

    recent years. The primary data sources that were examined as potential sources of records

    of historical natural gas curtailment are summarized in Table 1.

    Table1 Sourcesofcurtailmentinformation.

    SOURCENAME

    AVAILABLE

    STARTING

    DATE

    AVAILABLE

    ENDINGDATE NOTE

    ERCOTGasCurtailmentSurvey 9/13/1994

    (Earliest

    Curtailment

    Reported)

    4/1/2011(Latest

    Curtailment

    Reported)

    Responsestosurvey

    senttonaturalgas

    firedelectric

    generatorswithin

    ERCOT'sserviceregion

    aspartofthisstudy

    ERCOTOperatorLogs Dec2002 Aug2011 OperatorLogs

    providedbyERCOT

    filteredusingthekey

    wordsGas

    CurtailmentandGas

    Restriction

    ERCOTMonthlyOperationsReports Jan2004 Jul2007 FocusedonOperating

    ConditionNotice

    NationalEnergyTechnologyLaboratory

    (NETL)ElectricDisturbanceEvents(OE

    417)AnnualSummaries

    Year2000 Year2011 FocusedontheMajor

    ElectricDisturbances

    andUnusual

    Occurrences

    RailroadCommissionofTexas(TRRC)

    PipelineIncident

    Reports

    and

    separate

    responsetoERCOTDataRequest

    12/12/1983 2/2/2011 TRRCresponsetodata

    requestsent

    as

    part

    of

    thisstudy

    Secondary sources of data that were examined and utilized are listed in Appendix A Data

    Sources.

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    There was limited overlap between curtailment or disruption data available through

    natural gasfocused and powerfocused entities. NETL and other sources of curtailment

    data from powerfocused entities placed limited or no emphasis on capturing or reporting

    the natural gas fuel aspect of recorded events and, at best, natural gas curtailment could

    only be inferred for some of those incidents. Pipeline electronic bulletin boards and other

    natural gasfocused sources, in turn, did not capture impacts of gas curtailment events onelectric generators in detail although such impacts were inferred by Black & Veatch where

    possible. ERCOTs operator logs were most directly applicable of the various primary data

    sources reviewed. Documented gas curtailments outside of contractual agreements were

    relatively rare among the incidents reviewed with most curtailment incidents reviewed

    appearing to be contractually permitted.

    3.2SUMMARYOFHISTORICALCURTAILMENTS&CAUSES

    In all, 216 incident records were identified upon review of the various data sources that

    were examined. The majority of historical curtailment incidents reported for ERCOT were

    winter occurrences associated with freezing weather as shown in Figure 2. A key finding of

    those incidnents is that the majority of historical curtailments to electric generators withinERCOTs service region during freezing weather appear to have been contractually

    permitted and triggered by a temperature threshold. A small number of coldweather

    related incidents were

    attributed to physical

    disruption of upstream

    supply or

    infrastructure. A FERC

    NERC report8, for

    example, attributed a

    majority of the

    February 2011

    generation loss to

    problems with

    winterization related to

    plant operations and

    with a smaller portion

    attributed to gas supply

    loss from wellhead

    freezeoffs and field

    level infrastructure

    failures. Figure 3 shows a fishbone diagram9

    outling possible causes and effects leading togas system failure related to freezing weather. In a failure modes and effects analysis

    8Report on Outages and Curtailments During the Southwest Cold Weather Event of February 1-5, 2011,

    Federal Energy Regulatory Commission (FERC) and North American Electric Reliability Corporation

    (NERC), August 2011, 357 p.9 A fishbone diagram (also known as an Ishikawa diagram) is a tool used to identify failure pathways in a

    failure mode and effects analysis (FMEA). In the current study, fishbone diagrams are used to summarize

    108

    10

    2

    54

    0

    20

    40

    60

    80

    100

    120

    GASCURTAILMENT/

    FREEZINGWEATHER

    GASCURTAILMENT/PIPELINE

    OPERATION

    GASCURTAILMENT/

    TROPICALCYCLONE

    GASCURTAILMENT/

    UNKNOWNCAUSE

    NumberofIncidents

    GasCurtailmentIncidents&Causes

    Figure2Numbersofdocumentedgascurtailmentincidentsstudied.

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    (FMEA), these are possible causeandeffect strings that can affect gassystem performance,

    based on general historical experience. The precise causeandeffect string is not always

    expressly published for every curtailment event. The potential factors leading to gas supply

    disruptions due to freezing weather are 1) freezing of onshore gas wellheads, 2) onshore

    power grids trip and pipelines lose pressure as gas compressors and/or Supervisory

    Control and Data Acquisition (SCADA) systems lose power and 3) contractual provisionswith gas suppliers/transporters that allow curtailment of gas supply to power generators

    based on temperature thresholds.

    Figure3 Fishbonediagramforpossiblefreezingweathercausesofgascurtailments.

    Pipeline operations represented the next largest driver of natural gas curtailment incidents

    historically. Those incidents were caused by unscheduled maintenance and line ruptures.

    There were 10 reported incidents of gas curtailments related to pipeline disruptions in the

    data reviewed. In addition, 54 incidents of gas curtailment were reported without any

    specified cause although our further research showed that none were linked either to

    freezing temperatures in winter or tropical cyclone occurrences in summer. Since those

    how causative agents might lead to gas curtailments but without identifying likelihood of the alternative

    pathways.

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    incidents were not weatherrelated, they were assumed to be infrastructurerelated and

    grouped together with pipeline disruptions. Figure 4 shows a fish bone diagram examining

    the cause and effect leading to gas system failure related to pipeline disruptions.

    Figure4 Fishbonediagramforpossiblepipelinerelatedcausesofgascurtailments.

    Only 2 incidents of gas curtailments driven by tropical cyclones were observed in the

    reviewed data10. Figure 5 shows a fishbone diagram examining the possible causes and

    effects leading to gas system failure related to tropical cyclones. The three main failurepaths driven by tropical cyclones are 1) shutting of offshore platforms due to a storm in the

    Gulf of Mexico (GOM); 2) onshore flooding caused by excessive rainfall that impacts gas

    processing facilities; and 3) high winds associated with tropical storms knock down power

    lines and cutoff power to gas pipeline compressors and/or SCADA systems.

    10 Weather-related incidents in the ERCOT Operator Logs dated from 2002 and later. Major tropical

    cyclone landfalls and coastal flooding events occurred in 1989 and 2001 prior to first records in the

    ERCOT Operator Logs.

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    Figure5 Fishbonediagramforpossibletropicalcyclonerelatedcausesofgascurtailments.

    3.3BESTPRACTICES&LESSONSTOBELEARNED

    A relatively small number of curtailment incidents outside of contractual agreements were

    observed overall in the data reviewed as part of this study. This would indicate that natural

    gas supply has proven to be a reliable fuel source for power generators operating in ERCOT

    and that market liquidity and commercial agreements appear to largely be effective in

    procuring natural gas supply for electric generators. The growth of onshore unconventionalnatural gas resources in Texas may be expected to help make natural gas supply even more

    readily available for ERCOT generators.

    Survey responses indicate that some electric generators in the DallasFort Worth region

    have entered into contractual agreements that allow curtailment of their natural gas supply

    in the event of extreme cold weather which is driven in part by curtailment priorities

    defined by the TRRC. Appendix D of the report includes the Curtailment Plan requirements

    of the TRRC in more detail. In addition to regulatory requirements, contractual agreements

    also can reflect a tradeoff between the cost of firm supply and the costs for contractual

    interruption based on historical experience that natural gas supply is available when

    needed during most days of operation.

    Switching to oil was observed in historical data as a mitigation measure when gas

    curtailments were in effect due to contractual terms. It should be noted that the economics

    of switching may place restrictions on the ability to switch to oil going forward.

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    Connectivity to multiple pipelines or to storage facilities would provide both supply

    flexibility to minimize delivered gas supply costs and fuelsupply redundancy for generators

    when curtailed by one pipeline.

    Increased coordination between natural gas and power industry regulating agencies could

    help ensure crosscapture of information as the role of natural gas as a fuel source forpower generation continues to grow. If ERCOT is expected to monitor fuel impacts on the

    reliability of the electric grid, better data capture of curtailment incidents is needed. This

    study recommends the following measures to better capture information related to natural

    gas supply and curtailments to electric generators:

    Training of ERCOT operators to improve their familiarity with the natural gasinfrastructure will help to increase the data accuracy of operator logs. As identified in this

    study, the operator logs comprised the most compete data source recording the

    disruption of natural gas supply to electric generators within the ERCOT service region.

    Adding standardized questions on gas deliveryrelated issues into annual reportssubmitted by the electric generators will allow ERCOT to track and assess any trends

    associated with natural gas supply disruptions that electric generators experience. It will

    also help ERCOT to understand and manage gas supplyrelated risks.

    Continued and growing coordination between ERCOT and the TRRC in development ofreports for capturing and sharing information on gas supply delivery issues impacting

    electric generators. Coordinated actions can foster better data capture for both

    organizations.

    Review of gassupply agreements and gascurtailment policies could help determinewhether new policies or regulations are required to increase the reliability of ERCOT

    generation. In addition to cost considerations, contractual agreements that require

    curtailment of gas supply to generators or mandatory curtailment policies as defined by

    the TRRC may inhibit a power generators ability and motivation to acquire firm gas

    supply.

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    4.0NaturalGasInfrastructure&MarketTexas is the largest producer as well as consumer of natural gas in the U.S., contributing

    about onethird of the total production in the U.S. and consuming oneseventh (with over

    85% of it being consumed in the industrial and electricity generation sectors)11. As a

    consequence, Texas enjoys one of the most robust natural gas markets in North America

    with welldeveloped infrastructure that includes natural gas production facilities, natural

    gas processing facilities, interstate and intrastate natural gas pipelines and natural gas

    storage facilities.

    Texas leads all states in the U.S. in the number of pipeline miles with more than 21,000

    miles of interstate natural gas transmission pipelines and more than 130,000 miles of

    intrastate natural gas transmission and distribution pipelines making it one of the best

    connected and served markets in the U.S.12

    4.1 INTERSTATEPIPELINES

    Among the major interstate pipelines serving electric generators within ERCOTs service

    region are Texas Eastern Transmission, CenterPoint Energy, El Paso Natural Gas, NaturalGas Pipeline Company of America, Tennessee Gas Pipeline, and Transcontinental Pipeline

    (Figure 6). Most of these interstate pipelines transport production from the Gulf Coast

    region and flow north to serve the Midwest market and northeast to serve the East Coast

    markets of the U.S. El Paso Natural Gas moves gas produced in West Texas fields to serve

    the West Coast.

    Since those pipelines move gas that is produced in and near Texas to consumers in the

    Midwest, East Coast and West Coast, the other market destinations can be considered as

    representing competition for natural gas supply for electric generators within ERCOTs

    service region. The potential for gas supply disruption to electric generators within

    ERCOTs service region that is posed from competing demand served by these pipelines isone of the risk factors considered in this study and is discussed in detail in Section 5 and

    Section 6.

    11 Natural Gas Annual Supply & Disposition by State, US Energy Information Administration.

    http://www.eia.gov/dnav/ng/ng_sum_snd_dcu_nus_a.htm12 Texas Pipeline System Mileage, updated October 28, 2010,, Railroad Commission of Texas.

    http://www.rrc.state.tx.us/data/gasservices/vitalstats/mileage.php

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    Figure6

    InterstateNatural

    Gas

    Pipelines

    Serving

    ERCOT

    Generators

    4.2 INTRASTATEPIPELINES

    Texas holds the distinction of having the largest number as well as the most miles of

    intrastate pipelines in the U.S. Those pipelines gather and transport natural gas from

    supply basins in Texas to local gas distribution companies, electric generation and

    industrial and municipal consumers, as well as to connections with intrastate pipelines and

    interstate pipelines that transport this gas to enduse markets in the Midwest, East Coast

    and West Coast. The major players in the intrastate pipeline market include Atmos Energy

    Corporation, Enterprise Products Partners, L.P., Kinder Morgan Energy Partners, L.P. and

    Energy Transfer Partners, L.P. owning and operating multiple, large Texas intrastate

    pipelines between them (Figure 7). Texas intrastate pipelines are regulated by the TRRCand are subject to alternative regulations compared with those of FERCregulated

    interstate pipelines. The TRRCs oversight over intrastate pipelines is largely focused on

    safety and pipeline integrity with less oversight, when compared to FERCregulated

    pipelines, related to commercial issues. This can result in less transparency about the

    available capacity and the transportation costs associated with intrastate pipelines when

    compared to interstate pipelines. It should be noted, however, that the intrastate pipeline

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    market in Texas is highly competive when multiple pipeline or supply alternatives are

    available to an enduser.

    Figure7IntrastateNaturalGasPipelinesServingERCOTGenerators

    4.3 NATURALGASSTORAGEFACILITIES

    Natural gas is commonly stored in underground rock formations such as depleted oil and

    gas reservoirs or leached caverns in salt domes. Natural gas storage helps to match the

    relatively constant production profile of natural gas with its highly seasonal consumption

    pattern by creating flexibility in the market and allowing participants to storage large

    volumes of natural gas in summer when the traditional heating load is typically low and to

    use this stored gas in winter when the heating load increases. Texas stands fourth in theU.S. in total underground natural gas storage capacity with over 783 Bcf of storage

    capacity13. Figure 8 shows the underground natural gas storage assets within ERCOTs

    service region.

    13 Underground Natural Gas Storage Capacity, as of December 2010, updated December 29, 2011, US

    Energy Information Administration.

    http://www.eia.gov/dnav/ng/ng_stor_cap_a_EPG0_SAC_Mmcf_a.htm

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    In addition to helping balance the seasonal demand with relatively constant production,

    natural gas storage also offers shortterm flexibility to the natural gas market by being a

    source of supply when demand is higher than anticipated and being able to absorb supply

    when demand is lower than anticipated. It is this attribute of natural gas storage that makes

    it attractive to electric generators seeking to manage the daytoday volatility in their gas

    supply needs. Natural gas storage offers electric generators the ability to quickly accesssupply when their generation needs ramp up or an alternate destination for surplus natural

    gas supply when generation needs ramp down. High deliverability storage or storage with

    the ability to inject or withdraw high volumes of gas each day relative to the total storage

    capacity of the field offers the most flexibility to swing with the daily gas supply needs of

    electric generators.

    Storage assets in Texas include both regulated assets that are part of natural gas pipeline

    systems as well as standalone storage assets managed by independent operators.

    Figure8NaturalGasStorageAssetsinERCOTsServiceRegion

    4.4 ROLEOFGASCOMPRESSORS

    Gas production fields, storage fields and both intrastate and interstate pipelines depend

    upon gascompression technologies to sustain their operations. A significant loss of

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    compression can interrupt pipeline flows and threaten curtailment of gas deliveries to

    customers.

    Gas compressors are built on either reciprocating or centrifugal technologies and with

    either combustionpowered or electricpowereddrive driver technologies. Combustion

    driven compression historically has used gas provided by a pipeline and thereby has offered

    a significant level of selfsufficiency for pipeline operations. In contrast, electricdrive

    compressors depend upon electrical power which is purchased from an outside source (not

    controlled by the pipeline) which represents a risk factor beyond the control of the pipeline.

    Based upon Black & Veatch research, Table 3 summarizes the proportions of gas and

    electricdrive compressors installed in Texas. Although the numbers in Table 3 are not

    represented as a comprehensive inventory, the most significant message is that about 18%

    of all transmission pipeline compressors are electricdrive and therefore at risk to power

    outages. However, pipeline operations often are designed to be able to continue with

    limited compressor outages whether gas fired or electricdrive.

    Table2IndicativenumbersofnaturalgascompressorsservingtheTexasgaspipelineinfrastructure.

    COMPRESSOR

    TYPEGASFIELD

    TRANSMISSION

    PIPELINE

    UNDERGROUND

    STORAGETOTAL

    GasCombustion 4 498 34 536

    Electric 1 111 2 114

    Total 5 609 36 650

    Since the 1990s, the general trend among gas pipelines has been toward selection of

    electricdrive compressors based on benefits of lower maintenance costs, lower noise

    emissions and lower air emissions14. Any corresponding increase in risks of power outagesgenerally has been considered an acceptable tradeoff.

    4.5 SURVEYRESULTSOFNATURALGASINFRASTRUCTURESERVINGERCOTGENERATORS

    As part of this study, Black & Veatch conducted a survey, through ERCOT, of the natural gas

    fired electric generators within ERCOTs service region to assess the natural gas

    infrastructure serving their facilities. The survey requested information on the pipelines,

    local distribution companies (LDCs) and storage facilities serving each electric generator.

    The information provided through survey responses was supplemented by a number of

    data sources to create a compilation of the natural gas infrastructure serving electric

    generators within ERCOTs service region. The data sources utilized include FERC, TRRC,

    pipeline electronic bulletin boards (EBBs), the US Energy Information Administration (EIA),

    Black & Veatchs proprietary database underlying our large body of work in natural gas

    market analysis and thirdparty vendor data. While the individual survey results are

    confidential, we share the following observations summarizing the survey responses:

    14Factors That Influence the Selection of Electric Motor Drives For Natural Gas Compressors, Prepared

    for The INGAA Foundation, Inc. by Southwest Research Institute, SwRIProject 18-2090, April 1999, 58 p.

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    The survey on natural gas infrastructure was sent to 109 gasfired electric generatorswithin ERCOTs service region and 82% of electric generators fully or partially responded

    to the survey. The survey results summarized below are applicable to this population of

    respondents alone.

    There is diversity in the natural gas infrastructure serving the electric generatorssurveyed with multiple pipelines serving these generators, namely, 44 different natural

    gas pipeline systems delvering powergeneration fuel within ERCOTs service region. Of

    these 44 pipelines, 7 are interstate natural gas pipelines and 37 are intrastate natural gas

    pipelines. Figure 9 shows the top 10 pipelines serving the electric generators in ERCOTs

    service region.

    Approximately 60% of the generators that responded to the survey (corresponding to51,550 MW of nameplate capacity15) have access to more than one natural gas pipeline

    interconnect which can create redundancy in natural gas supply alternatives (Figure 10).

    Figure9NaturalGasPipelinesServingERCOTElectricGenerators

    15 The nameplate capacity is inclusive of generation capacity that is part of Private Use Networks which

    generally serve their own industrial loads rather than selling power into ERCOT.

    0

    5

    10

    15

    20

    25

    30

    Nu

    mberofGeneratorsServed

    NaturalGas

    Pipelines

    Serving

    ERCOT

    Electric

    Generators

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    Figure10NumberofPipelineInterconnectsforEachElectricGenerator

    All the generators that provided information on their capacity and peak needs noted thatthey had adequate pipeline capacity to meet their peak demand. Over 65% of these

    generators (corresponding to over 39,400 MW of nameplate capacity16) indicated that

    they had access to capacity in excess of 150% of their peak needs. Figure 11 shows thelevel of redundancy in pipeline capacity that was reported by the survey respondents. As

    seen in this histogram, many electric generators have access to substantial excess

    pipeline capacity that can be expected to increase their reliability of supply and offset the

    impacts of any supply or pipeline disruptions.

    Access to, or contracts for, gas storage appears to be limited, although storage is used on adaily basis by gas suppliers and interstate and intrastate pipelines to manage flows on

    their systems. Only 23% of the respondents reported information on natural gas storage

    as part of their supply portfolio.

    16 The nameplate capacity is inclusive of generation capacity that is part of Private Use Networks which

    generally serve their own industrial loads rather than selling power into ERCOT.

    37

    27

    16

    6

    4

    0

    5

    10

    15

    20

    25

    30

    35

    40

    1 2 3 4 5

    NumberofGenerators

    NumberofPipelineInterconnects

    NumberofPipelineInterconnectsForEachElectricGenerator

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    Figure11PipelineCapacityasPercentageofPeakNeeds

    Overall, based on the responses by generators to the survey, it appears that ERCOTs

    electric generators create reliability and redundancy of gas supply capability through their

    interconnections with multiple pipelines and access to a level of capacity that is well in

    excess of their peak natural gas needs.

    23

    11

    13

    4

    65

    7

    0

    5

    10

    15

    20

    25

    100%149% 150%199% 200%249% 250%299% 300%349% 350%399% >400%

    NumberofGenerators

    Capacityas%ofPeakDemand

    HistogramShowingPipelineCapacityas%ofPeakNeeds

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    5.0 RiskAssessment Approach&Assumptions

    5.1 SUMMARYOFAPPROACH

    Black & Veatch approached the risk assessment as a combined economic and quantitative

    analysis with the final objective being development of riskbased likelihoods of natural gas

    curtailments that could affect gasfired generation for scenarios that are specific to ERCOT.

    Our work effort for Deliverable 3 was focused on three main analytical efforts:

    A. Identification of ScenariosB. Probabilistic Analysis of ScenariosC. Fundamental Analysis of ScenariosA.IdentificationofScenarios

    This study utilized a scenariobased approach to assess the risk of gas supply curtailment to

    electric generators within ERCOTs service region. Black & Veatchs review of historical

    curtailment events provided the basis for selecting and shortlisting potential risk scenariosfor ERCOT to be analyzed in this study. As discussed in Section 3, freezing weather was

    found to be the most significant risk factor driving natural gas supply curtailment to electric

    generators within ERCOTs service region. Over 60% of the recorded incidents of gas

    supply curtailments to electric generators that were reviewed were driven by a freezing

    weather occurrence, including some driven by contractual provisions which stipulated

    temperature milestones in their curtailment schedules. Other risk factors that were found

    during our review of historical curtailments were pipeline disruptions and tropical

    cyclones. Accordingly, the scenarios shortlisted for the study are primarily weatherdriven

    or infrastructuredriven and listed below:

    1. Freezing weather in Texas and outside Texas2. Pipeline disruptions3. Tropical cyclonesFor each given scenario, the study examined a family of occurrences of increasing severity

    to facilitate understanding of the shape of the risk profile associated with a given risk factor

    as opposed to a point estimate of the risk.

    Notable historical curtailments where available were utilized as benchmarks within the

    scenarios analyzed.

    B.ProbabilisticAnalysisofScenarios

    The next analytical step was the probabilistic analysis of each of the scenarios to determinethe risk associated with their occurrence. Those analyses adopted an empirical approach

    which distinguished frequencies of potential causal events from frequencies of documented

    curtailment events17. Most notably, frequencies of occurrence of problematical weather can

    17 A causal event is an environmental or operational factor which, based on historical experience, could

    cause a gas curtailment event. For events associated with weather, it is possible to derive causal-event

    statistics which are independent of curtailment-event data.

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    be calculated for years where records for curtailment events do not exist. But the

    information of greatest interest remains in the curtailmentevent reports. Accordingly, the

    approach adopted in this study emphasized analysis of curtailmentevent data directly

    wherever possible.

    The probabilistic (stochastic) methodology employed the following sequence of actions:

    Compile curtailment event data for each scenario as defined by a causal relationship (forexample, freezing temperature, tropical cyclone, pipeline failure)

    For each scenario, differentiate the curtailment event data into subpopulations ifpossible (for example, curtailments associated with freezing temperatures or high

    heatingdegree day numbers either in Texas or elsewhere)

    For each population (or subpopulation) of curtailment events in each scenario, employstatisticalanalysis software to derive a bestfit probability distribution function (PDF)

    that describes frequency of event occurrence

    To the extent that documented reports allowed, derive PDFs

    that describe frequency oflost generation by size (MW) in each scenario (This was possible for freezingweather

    and pipelineoutage scenarios.)

    As necessary, mapover causaleventPDFs onto selected curtailment thresholdsexpressed in units of generation (MW). (This was necessary for tropical cyclones.)

    Employ the PDFs,alongwithscalingfactorsforgrowthordeclineofgasdependencies, toderive probabilities of occurrence of the subject hazard (curtailment event) at selected

    timeline thresholds (for example, 5 and 10year).

    The robustness of probabilistic results for causal events was strongest for weather data

    which comprised large, continuous data sets. Probabilistic results for curtailment event

    data carried much larger uncertainties associated with the much smaller and lesscontinuous nature of their data. For daily weather data compiled for winter months

    (December, January, February) over the period of January 1981 through February 2011, the

    data set available for each station typically comprised 2,766 measurements. In contrast,

    curtailment event data were typically limited to fewer than 100 incident reports (Table 3).

    After incidents were analyzed to define discrete events, and especially as subcategories

    were sought among the types of events, the data available to define a subscenario were

    reduced to 25 or fewer examples in many cases. For comparison, science and engineering

    analyses commonly find that the minimum number of samples required for application of

    distributionfunction statistics falls in the range of 155018 which, in the current study, is

    matched by the freezingweather and pipelineoutage incident reports but not by the

    tropicalcyclone incident reports (Table 3). Accordingly, analyses for freezingweather and

    pipelineoutage events proceeded directly using loss reports (typically MW rather than

    Bcf/d, based on relative numbers of available reports) but for tropicalcyclone incidents it

    18 The minimum sample size depends on the distribution function chosen but the minimum number

    generally increases as the function differs from a Normal (Gaussian) distribution. See, for example, Meyer

    S. L. (1975)Data Analysis for Scientists and Engineers, John Wiley & Sons, Inc., New York, 413 p..

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    was necessary to model indirectly using frequency of occurrence of tropicalcyclone activity

    and implied impacts on gas supplies which then were translated to equivalent MW losses in

    ERCOT. The effects of different sample sizes on goodnessoffit and on uncertainties (error

    bars) for risk levels is illustrated in Appendix B Weather Analysis.

    Table3. Sizesofcurtailmentincidentdatasetsavailablefordefinitionofeventsandprobabilisticrisk

    analyses.

    PERIOD

    OF

    RECORD

    FREEZINGWEATHER(1) TROPICALCYCLONE(2) PIPELINE(3)

    Total

    Incl.

    MW

    Loss

    Reports

    Incl.

    Bcf/d

    Loss

    Reports

    Total

    Incl.

    MW

    Loss

    Reports

    Incl.

    Dth/d

    Loss

    Reports

    Total

    Incl.

    MW

    Loss

    Reports

    Incl.

    Dth/d

    Loss

    Reports

    2011

    2002106 62 7 2 1 1

    2011

    198764 46 0

    (1)

    Excludes

    two

    other

    events

    (Dec

    1983,

    Dec

    1989)

    for

    which

    MW

    and

    Dth/d

    loss

    data

    were

    not

    available.

    Includes

    incidentscausedbycontractualprovisions.

    (2) Excludestwootherlandfallandfloodingevents(1989,2001)forwhichERCOTrecordsdonotexist.(3) Includes combination of events documented as pipeline plus other events documented as unknown but

    whereapipelineinvolvementwasinferred.

    C.FundamentalAnalysis

    For each scenario identified, Black & Veatch used a fundamental supplydemand model to

    examine the sufficiency of the natural gas infrastructure and natural gas supply to impact

    on natural gas service to electric generators in the ERCOT region. This analytical approach

    incorporates a network representation of the physical capabilities of the natural gas

    infrastructure in serving electric generators rather than the contractual obligations on the

    natural gas facilities. Although there may be financial implications to procuring the gassupply needed, natural gas service is available to electric generators subject to the

    regulatory and physical constraints of the system. In addition, procuring all the bilateral

    contracts required to comprehensively capture the contractual obligations within ERCOT is

    a significant, if not impossible, undertaking that is complicated by the lack of publicly

    available information.

    Black & Veatch estimated the natural gas demand or supply implications associated with

    each of the scenarios and used these modified demand and supply assumptions as inputs to

    the fundamental market model. The analysis examined any resulting constraints within the

    system (caused either through increased demand or decreased supply) that impacted the

    availability of natural gas supply to electric generators within the ERCOT region.

    The fundamental analysis is intended to supplement the probabilistic risk analysis by

    defining specific forwardlooking scenarios that examine the sufficiency of pipeline

    infrastructure and natural gas supply to meet the needs of electric generators in ERCOTs

    service region.

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    5.2TOOLSANDSOFTWARE

    Black & Veatch utilized a combination of tools to analyze natural gas markets and

    infrastructure related to ERCOTs Gas Curtailment Risk Study.

    ProbabilisticRiskModeling

    Probabilistic risk analyses were performed using the Palisade DecisionTools Professional5.0 software package which includes the module,@Risk, for stochastic simulation through

    Monte Carlo and Latin Hypercube algorithms. For each data set analyzed, the empirical data

    were passed through the @Risk bestfit functions using AndersonDarling criteria19 to

    identify the top candidates for describing the population as a mathematical function.

    Because the subject data represented physical phenomena20, for which negative values

    were not physically possible in some attributes21, analyses took care as appropriate to

    override the default @Risk settings which allow distributions with both negative and

    positive numbers in the output. The @Risk settings were adjusted as necessary to avoid

    negative tails where they were physically impossible.

    As is common with physical phenomena, the bestfit distribution functions tended to favorLogNormal, LogLogistic or Weibull distributions and less commonly a Normal (Gaussian)

    distribution. The Weibull and other logbased distributions are especially applicable to

    reliability analyses22. For a given data set, the best fit as indicated by AndersonDarling

    criteria was adopted for further analysis although the top three distribution candidates

    were used to estimate uncertainties (error bars) in the adopted distribution.

    NaturalGasInfrastructureAnalysis

    Black & Veatch utilized RBACs GPCMTM model as a basis to analyze the ERCOT and

    surrounding regions natural gas market infrastructure. The GPCMTM model operates using

    an algorithm to solve for optimal equilibrium price and quantities by balancing multiple

    demand and supply nodes in the market. As a network model, GPCMTM

    nodes representproduction regions, pipelines, storage facilities, and enduse customer groups. Black &

    Veatch supports GPCMTM with a detailed database of proprietary and public sources that

    was modified to support the assumptions and scenarios for this study.

    The GPCMTM model balances supply and demand from all the regions to find an equilibrium

    solution that maximizes producer profit and minimizes consumer cost. Based on Nobel

    Prizewinning economist Paul Samuelsons theory, the economically efficient, market

    clearing solution will dispatch lower cost supplies before more expensive ones and

    customers willing to pay more will be served before those willing to pay less. As shown in

    Figure 12, quantity (Q) supplied to market grows as price (P) rises from point of production

    19Anderson-Darling is one of several commonly applied tests for measuring the goodness-of-fit of

    distribution functions applied to real data. Compared with alternative methods, Anderson-Darling has been

    found to provide better performance for distributions with extensive tails.20 Physical phenomena studied here included both integer and decimal numbers. Integer representations

    included presence/absence of an incident or event. Decimal numbers included temperature, wind speed,

    heating-degree days or system impacts such as Dth/d or MW lost.21 Negative values are possible for temperature but not for other attributes studied, including wind speed,

    HDDs, Dth/d, MW and numbers of incidents or events.22 See Meyer S. L. (1975), op cit.

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    (Ps) to point of consumption (PD) until the cost of transportation exceeds market price and

    supply retracts. Namely, supplies from the supply region will continue to be transported to

    the consumption regions until either the price differentials between the two regions drops

    below the transportation cost or the transportation capacity between the two regions is

    exhausted. The resulting prices, consumption and production quantities represent market

    equilibrium.

    Demand Rich Region Supply Rich Region

    Figure12SupplyDemandFundamentals.

    One of the challenges of understanding the risk of gas curtailment to electric generators

    within ERCOT is to determine the demand placed on the pipelines serving these electric

    generators by other sources residential, commercial, and industrial demand within

    ERCOTs region as well as residential, commercial, industrial and electric demand from

    outside ERCOTs region that are served by the same pipelines. By representing the entire

    natural gas infrastructure within North America, the GPCMTM model offers an efficient and

    effective methodology to model the impact of the total demand on the pipeline networkfrom other sources within and outside of ERCOTs region. The fundamental model

    represents both interstate and intrastate pipeline segments.

    Black & Veatch utilized GPCMTM to assess the constraints on the natural gas infrastructure,

    represented as a network within the supply/demand model, in responding to demand from

    the electric generation sector within ERCOT under the different defined scenarios. For each

    scenario, a corresponding estimate of demand, supply and any applicable scenariospecific

    infrastructure constraints were defined.

    IntegratedMarketModeling

    Black & Veatch has developed an Integrated Market Modeling (IMM) process which is usedto prepare its integrated longterm view on energy markets, the Energy Market Perspective

    (EMP). In order to arrive at this market view, Black & Veatch draws on a number of

    commercial data sources and supplements them with our own view on several key market

    drivers, for example, power plant capital costs, environmental and regulatory policy, fuel

    basin exploration and development costs, and gas pipeline expansion.

    S

    Q

    P D

    S

    Q

    P D

    Q

    P D

    Q

    P

    S

    D

    Q

    P

    S

    D

    S

    Q

    P D

    S

    Q

    P D

    Q

    P D

    Q

    P

    S

    D

    Q

    P

    S

    D

    TransportationCosts

    PD

    PS

    S

    Q

    P D

    S

    Q

    P D

    Q

    P D

    Q

    P

    S

    D

    Q

    P

    S

    D

    S

    Q

    P D

    S

    Q

    P D

    Q

    P D

    Q

    P

    S

    D

    Q

    P

    S

    D

    TransportationCosts

    PD

    PS

    TransportationCosts

    PD

    PS

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    Figure13Black&VeatchIntegratedMarketModelingProcess

    EMP is an integrated view of natural gas and power markets across North America, and the

    northern portion of Baja California, Mexico, that is electrically interconnected to the U.S.

    The study period of 10 years is marked by expectations of significant growth in the use of

    natural gas for electric generation in North America driven by environmental policies and

    resulting coal retirements and the cost competitiveness of natural gas technology withother fuel sources on a fixed and variable cost basis. By providing a careful consideration of

    the multiplicity of factors impacting todays energy markets, the Black & Veatch EMP uses

    an integrated market analysis process to arrive at a comprehensive view of how the energy

    world can evolve from todays starting point, providing a sound framework for decision

    making. The EMP was utilized to provide underlying assumptions for this study.

    5.3GLOBALASSUMPTIONS

    To evaluate risks of gas curtailments which could impact power generation within ERCOT,

    Black & Veatch made assumptions which were necessary to enable objective analyses

    within a reasonable scope. Assumptions which apply to all aspects of the study were as

    follows:

    Natural gas markets in Texas operate efficiently and economically during theanalysis period and market liquidity or mandated curtailments do not comprise

    limiting factors contributing to risk of curtailment of gas supply to electric

    generators. Appendix E provides a detailed review of the liquidity of the natural gas

    market in ERCOT to support this assumption.

    Natural gas supply is projected to grow during the analysis period in the Lower48as shown in Figure 14 with growth in unconventional natural gas production led by

    shale gas offsetting declines in conventional natural gas production.

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    Figure14 Lower48NaturalGasSupplyProjection

    Natural gas supply in Texas is projected to flatten with declines in conventionalproduction being offset by growth in unconventional production, primarily from the

    Barnett Shale and Eagle Ford shale plays as shown in Figure 15.

    Figure15 TexasNaturalGasSupplyProjections

    Natural gas demand in the Lower48 is projected to grow over the analysis period asshown in Figure 16. Growth in gas demand for electric generation is the primary

    0

    10

    20

    30

    40

    50

    60

    70

    80

    2008 2010 2012 2014 2016 2018 2020

    Bcf/d

    Lower48NaturalGasSupplyProjections

    Conventional Shale CoalBedMethane LNG

    0

    2

    4

    6

    8

    10

    12

    14

    16

    18

    20

    2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

    Bcf/d

    Conventional Barnett EagleFord Haynes ville GraniteWash GOM&StateWaters

    TexasNaturalGasSupplyProjections

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    driver for growth in natural gas demand as environmental regulations and lower

    gas prices lead to an increased share for natural gas in the electric generation mix.

    Figure16 Lower48NaturalGasDemandProjection

    Natural gas demand in Texas is projected to increase as demand for natural gas forelectric generation increases as shown in Figure 17. Gasfired generation capacity

    within ERCOT is projected to increase by over 15,000 MW in the next 10 years and

    natural gas share of electric generation within ERCOT is projected to increase to

    50% over this time period.

    0

    10

    20

    30

    40

    50

    60

    70

    2008 2010 2012 2014 2016 2018 2020

    Bcf/d

    Residential Commercial Industrial Electric

    Lower48NaturalGasDemandProjections

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    Figure17 TexasNaturalGasDemandProjection

    Natural gas pipelines and storage facilities are represented in detail in thefundamental supplydemand model used in this study. In order to examine the

    sufficiency of the pipeline grid to serve the demand of electric generators within

    ERCOTs service region, electric generation facilities were grouped together on the

    basis of the natural gas pipelines serving them and their locations and linked (as

    demand nodes) to the pipeline network.

    Accuracy and precision of statistical analyses are limited by available curtailmentevent data. The different curtailment scenarios considered each offered different

    levels of data availability and allowed varying precision in the analytical effort of

    this study.

    This study takes a conservative view on the risk of gas curtailment to electricgenerators. No mitigating measures have been incorporated in developing the

    results presented here. In reality, when natural gas supply or delivery is impacted,

    the redundancy and interconnectedness in the natural gas market generally

    provides consumers (including electric generators) with alternate sources and

    routes for natural gas supply to partially or fully serve their needs. Pipeline

    linepack, natural gas storage and displacement of supply from other markets could

    all contribute to mitigate the risk of disruption of natural gas supply to electric

    generators within the ERCOT service region that are presented in this study.

    0

    1

    2

    3

    4

    5

    6

    7

    8

    9

    10

    2008 2009 2010 2011 20 12 2013 2014 201 5 2016 2017 2018 20 19 2020 2021

    Bcf/d

    Residential Commercial Industrial Electric

    TexasNaturalGasDemandProjections

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    6.0 RiskAssessment Results

    6.1 IMPLICATIONSFROMFREEZINGWEATHER

    6.1.1. ProbabilisticAnalysis

    AnalysisMethodology

    E